North Carolina Department of Environment and Natural Resources 

Division of Air Quality 

Michael F. Easley, Governor William G. Ross, Jr., Secretary 

B. Keith Overcash, P.E., Director 

December 13,2007 

Kay T. Prince 

Chief, Air Planning Branch 

USEPA Region 4 

Atlanta Federal Center 

61 Forsyth Street, SW 

Atlanta, GA 30303-3104 

Dear Ms. Prince: 

Thank you for your letter dated November 26, 2007, transmitting the U. S. Environmental 

Protection Agency's comments on the pre-hearing draft of the Regional Haze State 

Implementation Plan (SIP) for North Carolina Class I areas. I greatly appreciate you and your staff 

taking the time to review the pre-hearing draft documentation. 

Enclosed with this letter is our response to your comments. The North Carolina Division of Air 

Quality plans to submit its final Regional Haze SIP by December 17, 2007, the statutory deadline 

for regional haze plans. We hope to continue to work with you and your staff in the future as we 

monitor the progress in the North Carolina Class I areas of reaching natural background visibility 

conditions. 

If you should have any questions, please contact Laura Boothe of my staff at (91 9) 733-1488 or 

laura.boothe@ncmail.net. 

Enclosure 

CC: Laura Boothe 

Dick Schutt, USEPA Region 4 

Nacosta Ward, USEPA Region 4 

Michele Notarianni, USEPA Region 4 

1641 Mail Sewice Center, Raleigh, North Carolina 27699-1641 

2728 Capital Bivd., Raleigh, North Caroiina 27604 

Phone: 919-715-7670 1 FAX 919.715-7476 i Internet: w.ncair.org 

An Equal OpportunityiAfiirmative Action Employer - 50% Recycled/lO% Post Consumer Paper 

One NorthCarolina 
J~csponse to Comn~enls received by C. S. Environmental Protection Agency (IJSEI'A) 

USEI'A Comment: "The Regional Haze regulations in 40 CI'R 51.308(i)(3) require States to 

explain how they addressed the comments from the Federal Land Managers in their SIP. Please 

address 40 CFR 51.308(i)(3) in your final subniittal." 

NCDAQ Responscx Respoilses to the Federal Land Managers' (FLM's) comments will be 

iiiciuded as part orthc Jinal Iic$ional 1-Iazc State lmple~ncntalion Plan (SIP) as part of Appendix S 

Cons~lltation l'roccss. 

I.IS1<13A Comment: "Pages 8 and 9: 'I'lle estimation of natural background is an iinportant 

component of the tcchnical analyses in thc Regional I-Iazc S11'. We recommend that this section bc 

revised (or a new subsection added) to address tire ieclnnical manner in which ilatural background 

was developed for reasonable progress and for BART. Currently these discussions are presented 

in appendices without being specifically refereuced in the SIP Narrative. The discussion should 

reference the specific data ~ised in applying the new IMPROVE equation for the reasonable 

progress goal determinations presented in Table 2.3-1 ." 

IVCDAQ Response: Z,anguage will he added in the ha1 Regional Haze SIP to address this 

concern 

IJSEl'A Comment: "Pages 87 and 88: We suggest a clarification to the statement repeated on 

pages 87 and 88 as follows (see underlined text): "Since the BART determination takes into 

consideration many of the samc factors as for reasonable progress, the BART subject units were 

not re-evaluated in the reasonable progress review.'"' 

NCDAQ licsponse: The sl~ggesled ianguagc will be added in the final Regional [-laze SIP. 

USlWA Commcnt: "Scction 7.8, Step3: '1'0 f~lrthcr strengthen the State's justiiicatiou that the 

Clcan Air Intcrskte Rule (CAR) is suflicient for reasonable progress Sor subject clcctric 

geilcraiiilg units (I3GUs) during the first planning period, wc suggest to also include a reSereincc to 

tine language in the CAIR rule wlnich says, in summary, that the CAR controls are all that arc 

reasol~ahle ibr the compliance period of the rule. 

NCDAQ Response: Language will be added to the final Regional Haze SIP to address thls 

comment. 

USEPA Comment: "Section 11.0 and 12.0: The Skate makes several statements using terms such 

as the State "commits" to talie certain actions in the iirture, several of which are actions required 

by the rcgioslal haze regulations. The final SIP sl~ould make it clea if all of these actions are 

intended as mticipaied actions; which are unenforceable; or enforceable commitments. It is 

suggested that the State keep all enforceable coinmit~nents to those requirements already in the 

regional haze regulations and dislinguisli future aspirations w-it11 alternative language. We believe 

such language could be worded as, '"The State [anticipates or will likely or intends] to take 

[describe action]. . .", similar to what was done on page 11-66 under Step 3." 
IVCDAQ liesponse: The NCDAQ will rcvicw thc Language in Scction 1 I 0 and 12 0 and imalic 

the rccominend changcs 

USEPA Comment: "Section 12.0: We suggest a clarification to the following header (see 

yndcrlined icxt) such as, "List of Possible Actions --adapted from 40 CFR 5l.30R(h)," to clarify 

that provisions that follow also include a fcw items not specified in 51.308(h). 

NCDAQ liesponse: The suggested language will be addcd in the final Regional Haze SIP. 

liSEPA Comment: "Appendix 13; Section2.0 Uniform Rate ol' Progress, Pagc Appendix FI-19: 

This section states that VISTAS plans to present "glidepath" results for both the old and new 

II\/Il'IIOVE equation. This data should be added or a reference to the specific location in the 

Appendices should be provided." 

NCDAQ Response: A reference to Appendix A will be added to this section in the final Regional 

Haze SIP. 

1JSEPA Comment: "Aipendix 11, Scction 6.3, Process of Applying Statutory Factors: Pages 1-1- 

69-70: 'The discussion of the reasonable progress assessment for the PCS Phosphate facility 

discusses the BART and Prevention of Significant Deterioration (PSI)) evaliiations for two oi'tlie 

four units listed in the table on Page 1-1-71. No specific discussion is to support the s~atcniciit that 

"l3asically, no cost effective controls werc identified for the four units at this facility." Also, the 

discussion in this section should be updatcd to rcflcct t11c final outcome of'the BART 

determination for PCS Phosphate is? Appendix I>. 10. 

NCDAQ Response: Language to address this comment will be added in the final Regional Haze 

S11'. 

CJSEPA Comment: "H-74: In Section 8.1, the following paragraph needs to he updated to reflect 

the State has completed its BART determinations: "The NCDAQ is still in the process of 

reviewing the RAIIT determinations from the two facilities that werc determined to be subject to 

RAIZT. . . .'"' 

NCDAQ liesponse: This will be updated in the final SIP submittal 

USEPA Comment: "Appendix L. 10, PCS Phosphate BART Pre-hearing U)eterminatioil Analysis. 

Page L.10-470 & Appendix 13, Section 6.3, Process of Applying Statutory Factors, l'ages 1-1.69-70: 

The discussion of the BART assessments for the PCS Phosphate facility should address why 

ainmoiiia was not evaluated as a potential "visibility impairing pollutant." The VISTAS J3AR7' 

Sensitivity Analysis presented in Appendix L.3 indicates that PCS Phosphate is one of the ibur 

large sources of ammonia emissions in the soutlleast. 'The results of the VISTAS modeling 

aidyses indicate that ainmonia en~issions from I'CS I'hosphate could contributc to a visibility 

impact at the Swanquarter Class I area (see page L.3-11). 'The rationale for not evaluating 

ammonia emissions in the BART for PCS Phosphate should be providcd or the HART analysis 

should be revised to address the impacts of thc facility's ammonia emissions." 
NCDAQ licsponsc: This comment will he addressed in both Appcndix I~I and L by referencing 

thc fbllowing language in the PCS Phosphate BAIIT evaluation (Appendix 1..10-159): "Ammonio 

enzis.sions ure also minin?ized,fionz the DAI' I'luni Ilia. 3 as the ,rcruhheis uue inpluce,/br /mi? 

emissions control und,fi)r ainnmnia cuplure and recjicle to ihe process. Therefore, UART.for DAP 

No. 3 i.s no uddiiionul conlrol, as lhe plulzi is alreudji well-conlrolled and uddiiionul confrol is no/ 

cosi @xtive3'